On January 29, 2026, President Trump signed Executive Order 14380, “Addressing Threats To the United States by the Government of Cuba” (the “Executive Order”), in which he declared a national emergency with respect to Cuba and authorized the United States to impose new tariffs on imports from countries that directly or indirectly supply oil to the Government of Cuba. The Executive Order is accompanied by a White House Fact Sheet outlining the administration’s national security…
On February 2, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued General License 5U, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026,” to again delay the effective date of this authorization to March 20, 2026. This development is not related to recent developments in US sanctions targeting Venezuela, which we recently blogged about here. GL 5U authorizes…
On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 46 (“GL 46”) authorizing transactions related to the exportation/reexportation of Venezuelan oil prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. Our blog posts about recent developments under US sanctions targeting Venezuela can be found here, here, here, and here. Subject to certain conditions, GL 46 authorizes all transactions involving the Government of Venezuela…
Developments in Venezuela are raising new considerations for companies with operations in Venezuela and those that are considering business opportunities there, both in the energy sector and beyond. Finding the intersection of risk mitigation and opportunity requires understanding and balancing the legal, geopolitical and practical challenges that lie ahead. If you missed our first webinar on January 16, we’ve shared our key takeaways from the discussion here.